Privacy

Introduction

1. Journal Media Limited (‘we’, ‘us’ ‘our’) is committed to protecting your Personal Data. This Privacy Notice applies to your use of the websites and applications: TheJournal.ie, The42, FORA and DailyEdge (each, a “Site”) and sets out how we collect, use and protect your personal data. If you do not agree with the data practices described in this Privacy Notice, please do not use the Sites.

2. This notice (“Notice”) has been developed to inform our users about the privacy and security of personal data and to meet our obligations under the Data Protection Acts 1988 and 2003 and the General Data Protection Regulation (the “Data Protection Law”). Under Data Protection Law, personal data is information that identifies you as an individual or is capable of doing so (“Personal Data”).

3. We comply with Data Protection Law and this Notice applies to the personal data collected, processed and stored by us through your use of a Site.

4. For the purposes of Data Protection Law, we are the data controller of your Personal Data. You will find our contact details in the “Contact us” section below.

How we gather data and Personal Data

1. We gather data from your use of a Site for example through the use of cookies. We are not able to identify you from this data. You can find out how we use cookies and how to change your preferences in our Cookies Policy.

2. We gather Personal Data when you have logged in with a social media account or when you have provided us with Personal Data for example by contacting us via email or through the Site.

What kinds of Personal Data do we collect?

1. We receive and store information you enter on a Site or give us in any other way, including when registering for a commenting account, installing an application, subscribing to a mailing list, making a purchase, as well as provided in your comments and requests.

2. If, during your use of a Site, you log in with your social media account we will collect your social media account details as well as the name and e-mail address associated to that social media account (if available).

3. If, during your use of a Site, you post comments, we will keep a record of your commenting history.

4. The Sites create a user profile when you install an application. We will collect or process data you provide to us in the course of creating or updating a user profile. This information will vary but typically includes your device ID, the versions of our apps you have installed on your device, your reading interests in our Sites.

5. Our Sites offer location based features. When you enable these features we ask for your permission to access location data. We do not track your location.

6. If, during your use of a Site, you sign up to notifications or e-mail newsletters, we will also collect your preferences.

7. If you purchase goods we will collect your shipping address, order contact, payment method and purchase history.

Legal basis for processing

Given the varied functionality of each Site we rely on the following legal bases under Data Protection Law in processing your Personal Data:

How we may use your Personal Data

1. Except as disclosed in this Privacy Notice, we will not disclose Personal Data that we collect to any parties other than those with whom we partner or are affiliated with, without your consent. Except as disclosed below, we will not sell, share, trade, rent, or give away your Personal Data.

2. We may use your Personal Data to process any requests made by you for example, to create a user account, subscribe to a mailing list or make a complaint about a comment/post, respond to your inquiry, and communicate with you when necessary to provide customer service and/or follow-up information related to the Site. We may also use information you provide to communicate with you about your interest in our events and our company, to help us improve, operate and enhance your experience on a Site, to promote our events, notify you about important functionality changes to a Site, new services, and special offers we think you will find valuable, to tailor advertisements, content, and other aspects of your experience on and in connection with a Site, for other administrative purposes, to prevent or detect abuses of our terms of use, and to enable third-parties to carry out technical or other functions on our behalf as well as any other purpose that we may disclose to you at the point at which we request your Personal Data. We may combine non-personal information that you provide with supplemental information (including mailing address updates and demographic data) that we obtain from public sources or reputable third-parties. Information combined with personally identifiable information becomes, and is treated as, Personal Data under this Privacy Notice.

3. When you contact us, we may request your affirmative, positive consent to use your contact information for marketing or other business purposes. In the event you do not consent to the use of your contact information for marketing or other business purposes, your data will not be used for those purposes. If you provide your consent but subsequently do not wish to receive notifications about related opportunities,, you will be able to modify your preferences by following the instructions on any marketing correspondence.

Other websites

4. The Site interfaces social media websites such as Facebook and Twitter, and may use social media plugins (e.g., the Facebook "Like" button, '"Share to Twitter"' button) to facilitate social media functions.

5. If you are a member of a social media platform or website, and log in to such social media or platform, the interfaces may allow the social media platform or website to connect your visit to a Site to your Personal Data. The social media plugins also may allow the social media website to share information about your activities on a Site with other users of their social media platform. We have no control over the information that other websites or social media websites or plugins collect, store, or use. Before you choose to access other websites from a Site or “like” or share information from a Site through any social media platform or website, please be certain that you review the privacy notice of that social media platform or website.

Do we disclose Personal Data to anyone else?

6. We disclose customer information to third parties only when it is necessary as part of business practices or when there is a legal or statutory obligation to do so. Whenever we disclose customer information to third parties, we will only disclose that amount of information necessary to meet such business need or legal requirement. Third parties that receive customer information from us must satisfy us as to the measures taken to protect the personal data such parties receive, in accordance with Data Protection Law and as stated in this Privacy Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of customer information to third parties will be completed in a secure manner and pursuant to contractual safeguards.

7. We may employ other companies and individuals to perform functions on our behalf, including processing credit card payments, marketing, and providing analytics assistance. From time to time, we may also share Personal Data or non-personally identifiable information with third-parties that we have engaged to perform certain services in connection with the operation of certain aspects of a Site, including to customise, deliver, measure, analyse, improve and support our services, content, advertising and layout, your interaction with those aspects, and to deliver more relevant messages and advertisements to you. These third-party service providers are authorised to use Personal Data only if needed to perform their functions on our behalf and are required to maintain the security of your personal information.

8. Third Parties we work with

   The following is the list of companies we work with and may process data on our behalf. We include links to their privacy policy (available at the time of writing) for convenience:

   
   

   Google (Advertising, Analytics, Notifications, Office Software and Cloud Storage)
   Mailchimp (e-mail services)
   Facebook, Twitter and Linkedin (Social Media Authentication)
   Clickatell (SMS verification)
   Stripe, Paypal (Payments)
   Typeform (Surveys and forms)
   Shopify (e-Commerce)
   New Relic, Bugsnag (Error logs)
   Amazon AWS (Cloud computing)
   Pipedrive (CRM)

9. We may also change our ownership or corporate organisation while providing a Site. As a result, we may transfer your information to another company that is affiliated with us, with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Privacy Notice accordingly.

10. We may provide information, when obliged to do so under Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with Data Protection Law.

11. We may also provide information when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.

12. We may also disclose Personal Data in connection with any complaint regarding your use of the Site. For example, in the event of a complaint or legal action arising from a comment or content posted.

How long do we keep Personal Data?

1. The period for which we retain information varies according to the use of that information. In some cases, there are legal requirements to keep data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain information no longer than is necessary for the purposes for which the data were collected and processed (as described above).

2. User profiles may include personal data, for example when linked to a social media account. This information will be held for as long as you hold a user profile. Following the termination of a user profile we will retain the profile information for a period of up to two years.

3. Personal data collected from commenting will be kept for the lifetime of the article commented on.

4. Personal data submitted through participating in surveys will be kept for up to two years then aggregated (whereby the data is no longer personal data) and/or anonymised.

5. Following termination of the Terms of Use of a Site, your Personal Data shall continue to be retained for a period of seven years from the date of termination in accordance with Irish statutory limitation periods.

How do We protect data about you when or if it is transferred out of Europe?

6. Each Site is published in Ireland and is governed by Data Protection Law and Irish law.

7. We do not transfer any Personal Data outside of the EEA. However, certain third parties providing services to our Sites may transfer data outside of the EEA for example, for storage purposes. These third parties include, for example, Google, New Relic and Bugsnag. If this changes at any point in the future, this Privacy Notice will be updated to take account of this change. We only engage reputable third parties that provide appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.

How you can exercise your rights in respect of Personal Data we hold about you Your rights

1. We shall vindicate all your rights under Data Protection Law. These rights are as follows:

   • your right to withdraw your consent to the processing of Personal Data at any time

   • your right to request from us access to personal data and to have any incorrect personal data rectified

   • your right to the restriction of processing concerning you or to object to processing

   • your right to have your personal data transferred to another service provider

   • your right to have personal data erased (where appropriate)

   • information on the existence of automated decision-making, if any, as well as meaningful information about the logic involved, its significance and its envisaged consequences

   Vindication of your rights shall not affect any rights which we may have under Data Protection Law.

Exercising your rights, managing information and opting out

2. You may update or change information related to your account by updating the social media account linked to your profile, or by sending us an e-mail at privacy@thejournal.ie. You may request that your information be removed from a Site by e-mailing us at the address provided above. You may also unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails.

3. You can update or correct your Personal Data, remove it from our system or exercise any of your rights by making a request to us at the contact information provided below. If for some reason access is denied, we will provide an explanation of why access has been denied.

4. We will confirm your request within 21 days of receipt, and process your request within 30 days of receipt.

How does a Site protect personal information about you?

1. We employ reasonable appropriate administrative, technical, personnel procedural and physical measures to safeguard Personal Data against loss, theft and unauthorised uses access, uses or modifications. Security and testing are performed on systems containing personal data to verify control effectiveness. Security of these systems are monitored continuously.

2. While we try our best to safeguard your information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer

How can you make a complaint about the Use of Personal Data?

3. Complaints on the use, retention and disposal of personal data can submitted via email to privacy@thejournal.ie.

4. As a user of a Site you also have the right to lodge a complaint with the Data Protection Commission.

Review

1. This policy will be reviewed and updated from time to time to consider changes in the law and the experience of the policy in practice. Any and all changes will be advised to customers and, if necessary, we will obtain your consent prior to applying any changes to any Personal Data collected from you prior to the date the change becomes effective. Your continued use of a Site after such changes will be subject to the then-current policy. We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and disclose personal information.

Contact information

1. If you have questions about this Privacy Notice or our treatment of the information provided to us, please contact us at:

   Name: Journal Media Limited

   ATTN: Data Protection Officer

   Address: 4th Floor Latin Hall, Golden Lane, Dublin 8

   E-mail: privacy@thejournal.ie